Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
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